Infineon Technologies AG – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Infineon Technologies AG has established a rigorous governance process for its climate lobbying, with oversight by its Board and defined mechanisms to align both direct and indirect advocacy with the goals of the Paris Agreement. As the company explains, "Our Board sets the Business Conduct Guidelines as a guide for the day-to-day behavior and the business-related actions and decisions," and it ensures that "public policy engagement [is] strictly aligned with our Business Conduct Guidelines," underpinning accountability. Moreover, "All direct activities are reviewed and monitored to ensure a Paris-aligned lobbying approach," while indirect lobbying through trade associations is managed via a "management system that checks the consistency of the climate policy positions of our industry associations with our own positioning." Infineon analyzes associations’ statements on "Support for the Paris Agreement," "Advocacy of CO₂ pricing" and "Promotion of the expansion of renewable energies," enters into dialogue where positions diverge, and "reserves the right to terminate membership" if misalignment persists. The company further enhances transparency by regularly reporting on its trade association memberships and "actively disclos[ing] the largest contributions." These controls demonstrate strong governance by defining review procedures and corrective actions overseen by the Board. However, the company does not disclose a publicly available audit of its climate lobbying alignment or name an executive responsible for ongoing review. View Sources	3

Overall Assessment

Analysis

Score

Strong

Infineon Technologies AG has established a rigorous governance process for its climate lobbying, with oversight by its Board and defined mechanisms to align both direct and indirect advocacy with the goals of the Paris Agreement. As the company explains, "Our Board sets the Business Conduct Guidelines as a guide for the day-to-day behavior and the business-related actions and decisions," and it ensures that "public policy engagement [is] strictly aligned with our Business Conduct Guidelines," underpinning accountability. Moreover, "All direct activities are reviewed and monitored to ensure a Paris-aligned lobbying approach," while indirect lobbying through trade associations is managed via a "management system that checks the consistency of the climate policy positions of our industry associations with our own positioning." Infineon analyzes associations’ statements on "Support for the Paris Agreement," "Advocacy of CO₂ pricing" and "Promotion of the expansion of renewable energies," enters into dialogue where positions diverge, and "reserves the right to terminate membership" if misalignment persists. The company further enhances transparency by regularly reporting on its trade association memberships and "actively disclos[ing] the largest contributions." These controls demonstrate strong governance by defining review procedures and corrective actions overseen by the Board. However, the company does not disclose a publicly available audit of its climate lobbying alignment or name an executive responsible for ongoing review.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Infineon Technologies AG offers a moderate level of transparency regarding its climate-policy lobbying. It names two identifiable policy frameworks it engages on—the Paris Agreement and the EU Right to Repair regulation—and indicates support for economy-wide CO2 pricing and accelerated renewable-energy expansion, signalling the main areas where it seeks to influence legislation. The company discloses that it spent more than €800,000 on direct lobbying and that it works through over 20 industry associations, listing bodies such as the European Semiconductor Industry Association and the German Electro and Digital Industry Association; however, it does not identify the specific government agencies or lawmakers approached, nor the precise channels used beyond direct spending and association involvement. Infineon is clear about the outcomes it wants to secure, calling for stricter CO2 pricing, regulatory measures that promote micro- and power-electronics as enablers of a sustainable energy system, faster deployment of renewables, and the creation of competitive markets for green technologies, thereby providing concrete policy goals. The absence of detailed legislative references and named policymaking targets, though, leaves some aspects of its lobbying footprint opaque.	2